The Importance Of A Senior Executive Compliance Committee

by Michael Volkov

compcomm4People love to give advice – they love to tell people what to do (and hear themselves talk).   In order to be effective, compliance professionals have to be able to “listen.”  That means more than just being polite and paying attention when people speak.  The ability to “listen” means a willingness to consider new ideas, alternative strategies and approaches to compliance issues.

We all know that corporate boards play an all important role in an effective compliance program.  Not as much attention is paid to the operation of senior executive compliance committees.  This is a different animal than the compliance committee at the board level.  A senior executive compliance committee consists of the key senior corporate officers needed to carry out an effective compliance program.

A PWC Compliance Survey conducted last year found that 71 percent of surveyed companies have a senior executive compliance management committee.  But not all committees guarantee success.  Some committees work well and some do not.

The success of a committee depends on the mission, the structure and the processes of the committee.  The mission of a committee is defined by not only its role and responsibilities but whether or not it is empowered by the company to carry out its responsibilities.  The CEO and other senior managers have to commit the mission to the committee and make sure it has the backing of the company’s leadership.coia4

Assuming the senior executive compliance committee has the proper mission and is fully empowered, the membership of the committee is crucial to carry out its mission.  The compliance committee should include: (1) CEO; (2) CCO; (3) CFO; (4) General Counsel; (5) Chief, Internal Auditing; (6) Chief Operating Officer; (7) Human Resources; (8) Information Technology.

With these senior managers, compliance issues can be identified, assessed, and resolved, so long as the company maintains a commitment to compliance and this process.  This structure is essential to an effective compliance and ethics culture.

With a commitment from senior management and the appropriate structure, the senior executive compliance committee has to put in place effective processes to ensure that information is shared among the committee members, issues are identified for analysis and resolution, and business intelligence and plans are shared with key compliance players.

comcomm3Proactive management requires effective processes which elevate the right issues at the right time for the committee to resolve.  Technology has to be leveraged for the committee to succeed.  If technology is a hindrance, then the committee’s operations will be frustrated.

A compliance committee depends on integration of individual processes  into an integrated whole.

A compliance committee’s challenge is to align the right people, processes and technology to view risk across the company, and to ensure that key stakeholders on the committee have the right resources to implement a successful company-wide compliance program.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Michael Volkov, The Volkov Law Group | Attorney Advertising

Written by:

Michael Volkov

The Volkov Law Group on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Privacy Policy (Updated: October 8, 2015):

JD Supra provides users with access to its legal industry publishing services (the "Service") through its website (the "Website") as well as through other sources. Our policies with regard to data collection and use of personal information of users of the Service, regardless of the manner in which users access the Service, and visitors to the Website are set forth in this statement ("Policy"). By using the Service, you signify your acceptance of this Policy.

Information Collection and Use by JD Supra

JD Supra collects users' names, companies, titles, e-mail address and industry. JD Supra also tracks the pages that users visit, logs IP addresses and aggregates non-personally identifiable user data and browser type. This data is gathered using cookies and other technologies.

The information and data collected is used to authenticate users and to send notifications relating to the Service, including email alerts to which users have subscribed; to manage the Service and Website, to improve the Service and to customize the user's experience. This information is also provided to the authors of the content to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

JD Supra does not sell, rent or otherwise provide your details to third parties, other than to the authors of the content on JD Supra.

If you prefer not to enable cookies, you may change your browser settings to disable cookies; however, please note that rejecting cookies while visiting the Website may result in certain parts of the Website not operating correctly or as efficiently as if cookies were allowed.

Email Choice/Opt-out

Users who opt in to receive emails may choose to no longer receive e-mail updates and newsletters by selecting the "opt-out of future email" option in the email they receive from JD Supra or in their JD Supra account management screen.


JD Supra takes reasonable precautions to insure that user information is kept private. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. However, please note that no method of transmitting or storing data is completely secure and we cannot guarantee the security of user information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem by contacting us at In the unlikely event that we believe that the security of your user information in our possession or control may have been compromised, we may seek to notify you of that development and, if so, will endeavor to do so as promptly as practicable under the circumstances.

Sharing and Disclosure of Information JD Supra Collects

Except as otherwise described in this privacy statement, JD Supra will not disclose personal information to any third party unless we believe that disclosure is necessary to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of JD Supra, users of the Service, Website visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms & Conditions of Use.

In the event there is a change in the corporate structure of JD Supra such as, but not limited to, merger, consolidation, sale, liquidation or transfer of substantial assets, JD Supra may, in its sole discretion, transfer, sell or assign information collected on and through the Service to one or more affiliated or unaffiliated third parties.

Links to Other Websites

This Website and the Service may contain links to other websites. The operator of such other websites may collect information about you, including through cookies or other technologies. If you are using the Service through the Website and link to another site, you will leave the Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We shall have no responsibility or liability for your visitation to, and the data collection and use practices of, such other sites. This Policy applies solely to the information collected in connection with your use of this Website and does not apply to any practices conducted offline or in connection with any other websites.

Changes in Our Privacy Policy

We reserve the right to change this Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our privacy policy will become effective upon posting of the revised policy on the Website. By continuing to use the Service or Website following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, please do not continue using the Service or the Website.

Contacting JD Supra

If you have any questions about this privacy statement, the practices of this site, your dealings with this Web site, or if you would like to change any of the information you have provided to us, please contact us at:

- hide
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.